Randall Mark Jacobson - Page 7

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               Please return this information within 15 days of the date of           
               this letter.  If it is necessary to call you, please provide           
               your telephone number and the best time to call.                       
               On or about July 11, 1997, petitioner sent to respondent by            
          certified mail, the following letter:                                       
               This letter responds to your correspondence of May 30, 1997.           
               I have not received any previous request for my 1995                   
               Form 1040.                                                             
               Enclosed is a copy of my ammended [sic] 1995 Form 1040.                
               While reviewing documents, I noticed an error on line 18 of my         
               1993 Form 1040.                                                        
               Also enclosed is a copy of my ammended [sic] 1993 and 1994             
               Form 1040s.                                                            
          Accompanying this letter were unsigned copies of petitioner’s and           
          Evalyn’s Forms 1040 for 1993, 1994, and 1995.                               
               On or about July 31, 1997, respondent replied5 that the                
          material petitioner sent was inadequate, and that petitioner should         
          send signed copies of the Forms 1040, together with Schedules A, B,         
          C, and E.  In the meanwhile, on July 3, 1997, respondent had sent           
          notices of deficiency to petitioner for 1994 and 1995.  On August           
          26, 1997, respondent sent a notice of deficiency to petitioner for          
               Table 1 shows selected information from certain documents and          
          stipulations in the record.                                                 

               5The parties have stipulated that Exhibit 15-J is a “Letter to         
          respondent from petitioner concerning petitioner’s 1993, 1994, and          
          1995 federal income tax returns”.  Our finding is in accord with            
          Exhibit 15-J, which clearly is a letter to petitioner from                  
          respondent.  See supra note 3.                                              

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